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Program 30.2: Review and amend the Growth Management Program to reflect current housing and infrastructure conditions and current housing needs, and to ensure that the Growth Management Ordinance does not include constraints including preventing the City from meeting its share of the regional housing need for all income levels during the Housing Element planning period. Potential revisions include establishing a regional housing need allocation exemption for all lower income housing, incorporating all lower income regional housing need allocation requirements into the growth management allocation, and mandating the ability to "borrow" allocation units for lower income housing from future years to accommodate all levels of regional housing need allocation through the developer's development agreement, growth management agreement or other legislative act. As described by HCD, the concern with the current GMO, and to some extent previous GMO's, is that the City could reach its annual limit of allowable growth management unit allocations thus preventing an affordable home from being approved or proceeding with construction. To address this issue, staff identified three options as follows: a) Reestablish a set aside for affordable units that would only be available for affordable projects during any given year with the expectation that they would be "released" for market rate housing if not used. While this option is similar to language in previous GMO's (the most previous version set aside 50 affordable units annually), it still provides some level of constraints if the number of affordable units exceeds the annual set aside and therefore, does not fully address the HCD's concerns. b) Incorporate all lower-income regional housing needs allocation requirements into the growth management allocation. In essence this option is similar to the above except that rather than a modest number of units, approximately 50 to 100 per year, all 1,107 affordable units included as part of the total 2,067 RHNA units for this period would be set aside for affordable housing. While this option would assure that there are growth management units available for affordable housing, it fails to take into consideration that any available growth management unit allocation may be applied to affordable housing; thus, reserving this large amount may be excessive and result in possible double counting. c) The third option includes adding a provision to the GMO indicating that if the City Council approves an affordable housing development during a year in which the available number of growth management unit allocations has already been issued, then the Council would be obligated to "borrow" growth management units from a future year, even if that year is outside of the RHNA cycle. The current GMO allows for borrowing from a future year but it is at the discretion of the City Council. Further, the current GMO does not allow the borrowing of units from a future RHNA cycle. Staff is of the opinion that this option is the most appropriate since it assures that affordable units approved through the City's review process would receive growth management approval. Further, it would not "tie up" growth management unit allocations from being available for market rate housing. While the mandatory Page 5 of 7